VETTAIKKARANPUTHUR JANAGARAJ SELVA THYAGARAJ,COIMBATORE vs. ITO, WARD-1, POLLACHI

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ITA 2760/CHNY/2026Status: DisposedITAT Chennai25 August 2026AY 2017-184 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(A) did not properly consider the documentary evidence submitted by the assessee. Therefore, the issue was remitted back to the AO for fresh examination.

What were the facts?

The assessee did not file an income tax return, and the Assessing Officer (AO) reopened the assessment due to cash deposits during demonetization. The assessee claimed the deposits were from an agricultural loan, but the AO and CIT(A) did not accept this.

What were the issues?

Whether the CIT(A) properly considered the documentary evidence regarding the source of bank credits, and whether the AO should re-examine the issue.

Which sections of the Income-tax Act were involved?

Section 148,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & MS. PADMAVATHY.S

For Respondent: Mr. K.Jayaganesh, CIT

आयकर अपीलीय अिधकरण, ‘डी’ �ायपीठ, चे�ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH: CHENNAI �ी एबी टी. वक�, �ाियक सद� एवं सु�ी पदमावती यस, लेखा सद� के सम# BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND MS. PADMAVATHY.S, ACCOUNTANT MEMBER

ITA No.2760/CHNY/2026 �नधा�रण वष�/Assessment Year: 2017-18 VETTAIKKARANPUTHUR ITO, JANAGARAJ SELVA THYAGARAJAN, WARD-1 59, MITHILA HOUSE, WEST STREET, POLLACHI. VETTAIKARANPUDUR POST, Vs. POLLACHI TALUK, COIMBATORE-642129. अपीलाथ� / Appellant ��यथ�/ Respondent Permanent Account Number of Assessee: BDHPS 7734L

अपीलाथ� �वारा/Appellant represented by: Mr. Bhupendran, Advocate ��यथ� �वारा/Respondent represented by: Mr. K.Jayaganesh, CIT

सुनवाई की तारीख / Date of conclusion of hearing: 20-08-2026 घोषणा की तारीख / Date of pronouncement: 25-08-2026 आदेश / O R D E R PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, (in short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 03.03.2026 for Assessment Year (AY) 2017-18.

2.

The assessee is an individual and did not file the return of income. The A.O noticed that the assessee has deposited cash during the demonetization period into the bank account. Since the assessee did not file the return of

ITA No.2760/Chny/2026 Vettaikkaranputhur Janagaraj Selva Thyagarajan :- 2 -: income, the A.O reopened the assessment by issue of notice u/s.148 of the Act. The assessee neither filed the return of income in response to notice u/s. 148 of the Act nor did the assessee file any reply to the notices issued by the A.O. The A.O therefore treated the entire credits in the bank account as unexplained in the hands of the assessee. Aggrieved, the assessee filed further appeal before the CIT(A). The assessee submitted before the CIT(A) that the assessee has taken agricultural loan and the amount withdrawn from the loan account is credited to the SB account. The assessee further submitted that the supporting evidence for the ownership agricultural land was made available before the A.O which has not been considered. The CIT(A) did not accept the submissions and confirmed the addition made by the A.O.

3.

We have heard the parties and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee, during the course of hearing, submitted a paper book of 38 pages containing the details submitted by the assessee before the CIT(A) such as the agricultural loan statement, Patta of the agriculture land, bank book etc. The Ld. AR further submitted that the below table containing the details of source of bank credits:

ITA No.2760/Chny/2026 Vettaikkaranputhur Janagaraj Selva Thyagarajan :- 3 -: 4. From the perusal of the order of the CIT(A), we notice that the CIT(A) has not recorded any specific findings regarding the documentary evidence submitted by the assessee. We further notice that the CIT(A) has stated that the assessee did not upload any documentary evidence except the VAO certificate whereas the paper book by the Ld. AR substantiates the fact that the assessee has submitted various details including the agriculture loan statement which according to the assessee is the source for the bank credit in the SB account. Considering the facts and circumstances peculiar to assessee's case, we are inclined to give one more opportunity to the assessee in the interest of natural justice and fair play. Accordingly, we remit the impugned issue back to the A.O with a direction to examine the source as tabulated in the above table and to call for necessary details to decide the issue in accordance with law. The assessee is directed to submit the necessary details as may be called for and cooperate with the proceedings. It is ordered accordingly.

5.

In the result, the appeal of the assessee is allowed for statistical purposes.

Order pronounced on 25th day of August, 2026 at Chennai.

Sd/- Sd/- (एबी टी. वक�) (पदमावती यस) (ABY. T. Varkey) (Padmavathy.S) लेखा सद�य /Accountant Member �या�यक सद�य / Judicial Member चे�नई/Chennai, �दनांक/Dated: 25th August, 2026. EDN, Sr. P.S EJTADA Digitally signed by EJTADA DURGA NARESH DURGA Date: 2026.08.27 NARESH 16:34:07 +05'30'

ITA No.2760/Chny/2026 Vettaikkaranputhur Janagaraj Selva Thyagarajan :- 4 -: आदेश क� ��त!ल"प अ#े"षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड� फाईल/GF

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